The end of the year is a good time to assess the strength of your compliance program. SmartRIA’s Software as a Partnership® can help your compliance team keep tabs on the actions of your company and organize compliance to make it easy. Below are some things to keep in mind as 2022 approaches:
Prior to December 13, 2021, RIAs need to pay their renewal fees as indicated on the preliminary renewal statement available on the EBill section of the FIRM Gateway system. All registrations automatically expire as of December 31st but also automatically renew so long as the renewal fees are paid. If a firm fails to pay the renewal fees, they will enter the new year as a potential new applicant that is unable to provide advisory services or charge fees until a new registration is completed.
The firm will also receive a final renewal statement in January. This statement will include fees due based on any new registrations filed on or after November 8th through December 26th of 2021. This statement will also detail any refunds deposited into the Flex Fund Account for any registrations terminated between November 8th and December 26th.
No new registrations or terminations can be processed after 6:00 PM (ET) on December 26, 2021.
A short list of other end of year considerations for RIAs include:
- Log compliance training
- Determine an annual review action plan
- Consider Form 13F filing requirements
- Verify accuracy of Form U4
- Obtain employee certifications and acknowledgements
- Record any Code of Ethics enforcements and/or violations
- Confirm data protection and cybersecurity
- Confirm advertising, and social media reviews have been completed
- Review ADV disclosure brochures to prepare for the annual amendment
- Evaluate the records management system
- Confirm documentation of political contributions
- Review Third-party service providers
- Verify risk assessments are completed
Compliance is a complicated field. But it doesn’t have to be onerous. SmartRIA helps make the tasks of managing compliance less complicated for compliance officers, advisers and staff at your business. Schedule a demo here:
